STIPULATION AND PROPOSED ORDER FOR AN EXTENSION OF TIME OF 30 DAYS FOR DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT

EDMUND F. BRENNAN, Magistrate Judge.

IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that Defendant shall have an extension of time of an additional 30 days to respond to Plaintiff's motion for summary judgment. This is the second continuance sought by Defendant. The current due date is December 22, 2017. The new due date will be January 22, 2018.

There is good cause for this request. Since the Court's previous extension of time, Defendant's counsel has been diligently addressing her full workload including several district court cases also previously extended, and one Equal Employment Opportunity Commission matter involving discovery, depositions, and travel in November for a week. Moreover, in December, Defendant's counsel participated in a hearing for another employment case involving travel and that was unexpectedly continued twice, into the week of December 18, 2017, the same week as the original deadline for Defendant's response due Friday, December 22.

Moreover, Defendant is requesting an additional 30 days because of pre-approved leave in the months of December and early January, and additional unanticipated workload reasons, such as briefing for the employment hearing matter that was continued twice in December, described above.

Therefore, Defendant is respectfully requesting additional time up to and including January 22, 2018, to fully review the record and research the issues presented by Plaintiff's motion for summary judgment in this case. This request is made in good faith with no intention to unduly delay the proceedings.

The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

ORDER

APPROVED AND SO ORDERED.